On writ, the Court held that notice under section 148 issued on 23-4-2022 for assessment year 2015-16, being issued after 1-4-2021, was beyond limitation and therefore without jurisdiction. Consequently, reassessment order, demand notice, penalty notices/orders and recovery notices were quashed and set aside .  Followed, UOI v. Rjeev Bansal (2024) 301 Taxman 238/ 469 ITR 46 (SC) (AY. 2015-16]